The Ninth Circuit has denied a petition for review filed by a Gambian lawful permanent resident convicted of conspiracy to distribute methamphetamine, holding that his conviction was a particularly serious crime barring withholding of removal. The petitioner separately feared persecution in The Gambia based on a fatwa allegedly issued against him after a radio interview in which he described unorthodox religious views.
The Court held that the strong presumption from Matter of Y-L- that drug trafficking aggravated felonies are particularly serious crimes also triggers the regulatory presumption that the person is a danger to the community, without requiring a separate dangerousness finding. The Court declined to overrule its own precedent deferring to that presumption under the now-abrogated Chevron framework, explaining that Loper Bright's overruling of Chevron does not itself unsettle prior decisions that relied on it, under the doctrine of statutory stare decisis.
The full text of Sarr v. Blanche can be found here: https://cdn.ca9.uscourts.gov/datastore/opinions/2026/07/07/24-5264.pdf